Candidate Privacy Notice
What is the purpose of this document?
Crossroads Caring Scotland (CCS) is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. You are being provided with a copy of this privacy notice because you are applying for work with us (whether as an employee, worker, volunteer or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment and onboarding process, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).
We will use your application data for the purposes of recruitment and onboarding and where applicable to create an employment record.
We may also use some information on an anonymous basis for monitoring and reporting.
Data protection principles
We will comply with data protection law and principles, which means that your data will be:
Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.
The kind of information we hold about you
In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:
The information you have provided to us in any curriculum vitae and covering letter.
The information you have provided on our application forms, including name, title, address, telephone number, personal email address, employment history, qualifications, skills, professional registration and referees.
Any information you provide to us during an interview or other selection process.
In order to comply with our obligations under legislation and Safer Recruitment Guidance we will collate information relating to your Right to Work in the UK and identification evidence required to process a Disclosure Scotland application.
We may also collect, store and use the following "special categories" of more sensitive personal information:
Information about your age, gender, nationality, race or ethnicity, religious beliefs, sexual orientation, marital or civil status, health, and caring responsibilities. Not all of this information is mandatory.
Information about your health, including any medical condition, health and sickness records.
Information about criminal convictions and offences.
How is your personal information collected?
We collect personal information about candidates from the following sources:
You, the candidate.
Disclosure Scotland in respect of criminal convictions. We may also collate information from similar relevant agencies in any previous country of residence.
Your named referees, from whom we collect the following categories of data: dates of employment, suitability for the role, absence, disciplinary record and where relevant suitability to work with vulnerable adults and/or children.
Data from the following third parties such as: – professional registration, eg SSSC, NMC
Occupational health services
A recruitment agency acting on behalf of CCS
How we will use information about you
We will use the personal information we collect about you to:
Assess your skills, qualifications, and suitability for the role.
Carry out background and reference checks, where applicable.
Communicate with you about the recruitment process.
Keep records related to our hiring processes.
Comply with legal or regulatory requirements.
It is in our legitimate interests to decide whether to appoint you since it would be beneficial to our organisation to appoint someone to that role or to work for us.
We also need to process your personal information to decide whether to enter into a contract of employment with you. Having received your application form, we will then process that information to decide whether to progress your application. If we do, we will decide whether to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role or work. If we decide to offer you the role or work, we will then take up references, right to work check, carry out a criminal record check, a professional registration check and complete a pre-employment occupational health check, before confirming your appointment.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, as we require references for this role, if you fail to provide us with relevant details, we will not be able to take your application further.
How we use particularly sensitive personal information
We will use your particularly sensitive personal information in the following ways:
We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview or other selection process.
Following a conditional offer of employment, we will use information received from Occupational Health to determine any reasonable adjustments required to enable you to take up the role and if those adjustments can be accommodated.
We will use information about your age, gender, nationality, ethnic origin, religious, philosophical or moral beliefs, sexual orientation, health and caring responsibilities to ensure meaningful equal opportunity monitoring and reporting.
Information about criminal convictions
We will process information about criminal convictions.
We will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We are required and/or entitled to carry out criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role for which you have applied. In particular:
We are legally required under the Protection of Vulnerable Groups (Scotland) Act 2007 to carry out criminal record checks for those carrying out regulated work with vulnerable adults or children.
Roles involved in providing a registered care service, which do not work directly with vulnerable adults or children are included on the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (SI 1975/1023)] and are also specified in the Police Act 1997 (Criminal Records) Regulations (SI 2002/233)] so are eligible for a Standard check from Disclosure Scotland.
National Office roles require a high degree of trust and integrity since it involves dealing with service user information, employee information and finances and so we may ask you to seek a basic disclosure of your criminal records history.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
Automated decision-making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Data Sharing
Why might you share my personal information with third parties?
We will only share your personal information with the following third parties for the purposes of processing your application or where legally required:
where you have been recommended by a recruitment consultancy.
CCS occupational health provider
Referees named in your application. Where we wish to seek additional references, we will discuss this with you and obtain your consent.
Disclosure Scotland
Care Inspectorate
Electronic signature provider
(CCS IT providers)
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Our websites are protected with SSL certificates to secure and encrypt website traffic. CCS has achieved the Cyber Essentials certification.
Data retention
How long will you use my information for?
We will retain your personal information for a period of six months after we have communicated to you our decision about whether to appoint you to work for us. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations. If you are successful, your personal information will be transferred to an employment record file and you will receive further information regarding this.
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
Where you commence an application on the CCS website and save it to continue later, data entered will be encrypted and stored in the website database for 30 days. If you do not return to submit a full application within that period, the data will be automatically deleted.
Rights of access, correction, erasure, and restriction
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection at CCS in writing.
Right to withdraw consent
When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact the Recruitment Team at CCS, recruitment@crossroads-scotland.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.
If you have any questions about this privacy notice or how we handle your personal information, please write to Data Protection on the details given below.
Crossroads Caring Scotland
24 George Square
Glasgow
G2 1EG
0141 226 3793
info@crossroads-scotland.co.uk
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.
The Information Commissioner’s address is:
Information Commissioner’s Office
Wyclifffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline: 0303 123 1113
ICO website: https://www.ico.org.uk